Agenda

Nov 16, 2026
3:00 pm - 4:00 pm EST

In July of 2026 the federal regulatory agencies issued joint interagency guidance reminding institutions of their “existing obligations” regarding credit risk management when lending to borrowers who are not legally authorized to work in the United States. What does this mean exactly? Can we not lend to such individuals? Would it be a violation to do so? And how would we even know? What sorts of documentation should we be asking for?

We’ll be addressing these questions and more in this session, by discussing what you can and cannot do here, including whether this constitutes discrimination on any prohibited basis. Will we get in trouble if we do continue to lend to such individuals? We’ll also talk about your internal policies and procedures and think of them from a BSA/CIP perspective, so that you can make the best and most educated decisions for your institution.

Topics

KEY WEBINAR TAKEAWAYS:

• What this guidance really says and means – what you can and cannot do (or should or shouldn’t do)
• Impacts to your lending operations, as well as customer identification
• Important documentation
• How this dovetails with existing fair lending and BSA/AML requirements

Speaker(s)

Carl Pry, CRCM, CRP

Carl Pry is a senior advisor at Asurity Advisors and the founder of PryHart Compliance Services, Inc. He holds a JD and an MBA from the University of Toledo and a BSBA from Bowling Green State University. He is a seasoned executive with banking law, corporate finance, and regulatory compliance experience in Fortune 500 institutions, regional banks, and industry consulting firms.

Over the last 35 years, Carl has held senior leadership positions at Treliant LLC, KeyBank, Accenture, and the Kirchman Corporation. He is a frequent contributor to and currently serves as co-chair of the Editorial Advisory Board for the ABA Risk and Compliance Magazine. He has served as an instructor at FDIC examiner school and as a back-up instructor at NCUA examiner school. He has authored training programs covering consumer and commercial compliance, audit, quality control, tax, privacy, and risk management, among others.

Fees

Live Webinar - $279

• Unlimited connections for your institution
• Available on desktop, mobile & tablet
• Take-away toolkit
• Presenter’s contact info for questions

On-Demand Webinar - $279

• Unlimited & shareable access starting two business days after live stream
• Available on desktop, mobile & tablet devices 24/7
• Take-away toolkit
• Ability to download webinar video
• Presenter's contact info for questions

Live + On-Demand - $379

Get the best of both and save when you Bundle the Live & On-Demand Webinar registration! This option includes all the items listed above.

**100% surcharge applied to non-members.

Association Contact